Crypto-assets are often associated with high price volatility. However, some crypto-assets are designed to maintain a relatively stable value by referring to reserve assets. These assets are generally known as stable crypto-assets or, more commonly, stablecoins.

Under Turkish law, Law No. 7518 does not provide a detailed statutory regime specifically for stable crypto-assets. However, the general reasoning of the Law refers to a distinction between “stable” and “non-stable” crypto-assets. This distinction is important because it shows that the Turkish legislator recognizes that crypto-assets may have different economic functions and risk profiles.

What Are Stable Crypto-Assets?

In the general reasoning of Law No. 7518, stable crypto-assets are described as assets that aim to maintain a stable value by referring to money, commodities, crypto-assets, similar assets or combinations of these reserve assets.

Based on this explanation, stable crypto-assets may be understood as digital assets designed to reduce volatility by linking their value to a reference asset or a group of assets.

These reference assets may include:

Currencies,

Commodities,

Other crypto-assets,

Combinations of different reserve assets,

Other similar economic values.

The main purpose of stable crypto-assets is to offer a more stable value within the crypto-asset market.

Stable and Non-Stable Crypto-Assets

One of the notable aspects of the general reasoning of Law No. 7518 is the distinction between stable and non-stable crypto-assets. This distinction shows that crypto-assets should not be treated as a single uniform category.

Stable crypto-assets are designed to maintain value by referring to reserve assets. Non-stable crypto-assets, on the other hand, may be understood as crypto-assets that do not have such a value-stabilization mechanism.

This distinction may be important in practice. The risks of a crypto-asset backed by reserve assets are different from the risks of a crypto-asset whose price depends entirely on market supply and demand.

Therefore, stable crypto-assets may require a separate regulatory approach, particularly in relation to reserve transparency, investor protection and market reliability.

Importance of Reserve Assets

The concept of reserve assets lies at the center of stable crypto-assets. The reliability of a stable crypto-asset often depends on the nature, amount, custody and auditability of the reserve supporting it.

For example, if a crypto-asset claims to maintain its value by reference to a particular currency, it becomes important to determine whether the reserve actually exists. It is also important to assess where the reserve is held, who manages it, whether it is independently audited and how users are informed about it.

For this reason, stable crypto-assets should not be assessed only from a technological perspective. Reserve management, transparency and audit mechanisms are also essential legal and regulatory issues.

Stable Crypto-Assets Linked to the Turkish Lira

One important issue under Turkish law is how stable crypto-assets linked to the Turkish Lira may be treated in the future.

A crypto-asset designed to maintain its value by reference to the Turkish Lira may raise questions under several areas of law, including payment services law, electronic money law, capital markets law and crypto-asset regulation.

Turkish Lira-based stable crypto-assets may have potential use cases in digital payments, international transfers, tourism, e-commerce and crypto-asset markets. However, they also raise important legal questions, such as:

How will the Turkish Lira reserve be protected?

Who will audit the existence of the reserve?

Will users have redemption or repayment rights?

Could such an asset be classified as electronic money?

May crypto-asset service providers list these assets?

How will the liability of issuers be determined?

These questions show that stable crypto-assets linked to the Turkish Lira may require further regulatory clarification.

Are Stable Crypto-Assets Electronic Money?

Stable crypto-assets may have certain similarities with electronic money, especially where they are linked to an official currency. However, under Turkish law, not every stable crypto-asset can automatically be classified as electronic money.

Electronic money is a specific legal concept regulated under Law No. 6493. For a value to qualify as electronic money, it must meet the conditions set out under that law, including issuance against funds, electronic storage and use in payment transactions.

Stable crypto-assets may have different technical and economic structures. Some may be issued by a centralized entity, some may be backed by reserve assets, and others may attempt to maintain value through algorithmic mechanisms.

Therefore, whether a stable crypto-asset qualifies as electronic money must be assessed separately in each case.

Importance for User Protection

Stable crypto-assets may be perceived by users as safer digital assets because of their intended value stability. However, the word “stable” does not mean that these assets are risk-free.

Lack of sufficient reserves, non-transparent management, liquidity problems, technical failures, cybersecurity incidents or loss of market confidence may cause serious losses even in stable crypto-assets.

For user protection, the following issues are particularly important:

Clear disclosure of reserve assets,

Independent audit of reserves,

Transparent risk warnings,

Redemption and repayment conditions,

Liability of the issuer,

Transparent listing criteria by platforms.

If these issues are not clearly regulated, stable crypto-assets may create higher risks than users expect.

Role of Crypto-Asset Platforms

Stable crypto-assets are often traded on crypto-asset platforms. Platforms may facilitate their purchase and sale, display them in user accounts and provide custody-related services.

For this reason, platforms should carefully assess stable crypto-assets before listing them. The reserve structure, legal status of the issuer, technical security, user rights and risk disclosures should all be taken into account.

For platforms, the following issues may become important:

Which reserve assets support the stable crypto-asset,

Whether the reserves are auditable,

Who the issuer is,

Whether users have redemption rights,

The platform’s liability in case of loss or unauthorized transfer,

The adequacy of information provided to users.

These issues are important both for regulatory compliance and for the contractual relationship between platforms and users.

Need for Further Regulation under Turkish Law

Stable crypto-assets are one of the areas where Turkish law may require more detailed regulation. The reference to this concept in the general reasoning of Law No. 7518 is an important starting point. However, the statutory text does not yet contain a comprehensive regime for stable crypto-assets.

Further regulation may be needed on issues such as:

The definition of stable crypto-assets,

The nature and custody of reserve assets,

Audit of reserves,

Obligations of issuers,

Redemption and repayment rights of users,

Listing and disclosure obligations of platforms,

The relationship between stable crypto-assets and electronic money law,

The special treatment of Turkish Lira-based stable crypto-assets.

Clearer rules in these areas would contribute to user protection, market reliability and legal certainty in the Turkish crypto-asset market.

Conclusion

Stable crypto-assets are an important concept under Turkish crypto-asset law. Although Law No. 7518 does not provide a detailed statutory regime for these assets, the general reasoning of the Law refers to stable crypto-assets and distinguishes them from non-stable crypto-assets.

Stable crypto-assets aim to maintain a stable value by referring to reserve assets such as money, commodities, crypto-assets or combinations of these assets. For this reason, they are particularly important for both crypto-asset markets and payment-related use cases.

However, “stable” does not mean risk-free. Reserve structure, issuer liability, platform responsibilities, user rights and the relationship with electronic money law must be carefully assessed.

More detailed regulation of stable crypto-assets under Turkish law would be important for market reliability, investor protection and legal certainty.